FFIEC BSA/AML Examination Manual

Appendix H: Request Letter Items (Core and Expanded)

• List of all payable through relationships with foreign financial institutions as defined in 31 CFR 1010.605. • Access to contracts or agreements with foreign financial institutions that have payable through accounts. • List of the bank’s foreign branches and the steps the bank has taken to determine whether the accounts with its branches are not used to indirectly provide services to foreign shell banks. • List of all foreign correspondent bank accounts and relationships with foreign financial institutions that have been closed or terminated in compliance with the conditions in 31 CFR 1010.630 (i.e., service to foreign shell banks, records of owners and agents). • List of foreign correspondent bank accounts that have been the subject of a 31 CFR 1010.520 (Information Sharing Between Federal Law Enforcement Agencies and Financial Institutions) or any other information request from a federal law enforcement officer for information regarding foreign correspondent bank accounts and evidence of compliance. • Any notice to close foreign correspondent bank accounts from the Secretary of the Treasury or the U.S. Attorney General and evidence of compliance. • Make available copies of policies, procedures, and processes for complying with 31 CFR 1010.630. • List of all the bank’s embassy or consulate accounts, or other accounts maintained by a foreign government, foreign embassy, or foreign political figure. • List of all accountholders and borrowers domiciled outside the United States, including those with U.S. power of attorney. Currency-Shipment Activity • Make available records reflecting currency shipped to and received from the Federal Reserve Bank or correspondent banks, or reflecting currency shipped between branches and their banks’ central currency vaults for the previous ___________ months. ( Examiner to insert a period of time appropriate for the size and complexity of the bank.) Other BSA Reporting and Recordkeeping Requirements • Record-retention schedule and procedural guidelines. • File of Reports of International Transportation of Currency or Monetary Instruments (CMIR). • Records of Report of Foreign Bank and Financial Accounts (FBAR). OFAC • Name and title of the designated OFAC compliance officer and, if different, the name and

title of the person responsible for monitoring OFAC compliance. • Organization charts showing direct and indirect reporting lines.

FFIEC BSA/AML Examination Manual

H–5

2/27/2015.V2